Revision of European Ecolabel Criteria for industrial and institutional automatic dishwasher detergents

Transcription

1 Revision of European Ecolabel Criteria for industrial and institutional automatic dishwasher detergents Technical report and draft criteria proposal (TASK 5) For the 1 st AHWG meeting (Draft) Renata Kaps, Galyna Medyna, Alicia Boyano (JRC-IPTS Seville) Josie Arendorf, David Parker (Oakdene Hollins) December 2014

2 Table of Contents 1 INTRODUCTION PRELIMINARY REPORT SUMMARY AND LINKS TO THE REVISION AND/OR DEVELOPMENT OF THE EU ECOLABEL CRITERIA SUMMARY OF THE FEEDBACK REQUESTED FROM STAKEHOLDERS CRITERIA STRUTURE COMPARISON TABLE NAME AND DEFINITION COMPARISON TABLE COMPARISION OF EXISTING AND PROPOSED CRITERIA REVISION OF MAIN DECISION TEXT Name, definition and scope for EU Ecolabel Definitions TECHNICAL REPORT / CRITERIA PROPOSALS Assessment and verification requirements and measurement thresholds Functional unit (reference dosage) Criterion 1: Toxicity to aquatic organisms: Critical Dilution Volume (CDV) Criterion 2: Biodegradability Criterion 3: Excluded or limited substances and mixtures Criterion 4: Packaging requirements Criterion 5: Fitness for use Criterion 6: Automatic dosing systems Criterion 7: User information Information appearing on the EU Ecolabel Criterion NEW - Sustainable sourcing of palm oil, palm kernel oil and their derivatives...56

3 List of Tables Table 1: Link between the hotspots identified (LCA and non-lca impacts) and the revised EU Ecolabel criteria... 4 Table 2: Hazard statements Table 3: Derogated substances - To be discussed in the 1st AHWG meeting Table 4: Materials and components excluded from packaging elements Table 5: CDV data gathered for IIDDs Table 6: CDV levels for Nordic Swan Table 7: Summary of the phosphorus ecolabel criteria in selected schemes... 46

4 1 INTRODUCTION The following Technical Report presents a proposal of revised EU Ecolabel criteria for the product group of "industrial and institutional automatic dishwasher detergents" (IIDD). The study has been carried out by the Joint Research Centre's Institute for Prospective Technological Studies (JRC-IPTS) with technical support from Oakdene Hollins and PRé Consultants. The work is being developed for the European Commission's Directorate General for the Environment. The recommendations for the revision of the current criteria are based on technical analysis, including a Life Cycle Assessment (LCA) assessing the environmental impacts of products covered by the scope of the product group and other evidences, and input received from stakeholders. This document is complemented by the Preliminary Report on the revision of the European Ecolabel criteria for Industrial and Institutional Automatic Dishwasher Detergents 1 and a Technical Annexe. The Preliminary Report covers in detail areas such as: scope and legislative analysis (Task 1), market analysis (Task 2), technical analysis (Task 3) and improvement potential (Task 4). The Technical Annexe is common to all detergent product groups as they share common issues and the revisions of their EU Ecolabel criteria are being done at the same time in order to facilitate harmonisation between criteria, where appropriate. In all, there are six sets of EU Ecolabel criteria in the detergent product groups. These are: - laundry detergents (LD), - industrial and institutional laundry detergents (IILD), - detergents for dishwashers (DD), - industrial and institutional automatic dishwasher detergents (IIDD), - hand dishwashing detergents (HDD), - all-purpose cleaners and sanitary cleaners (APC). The present document is specific to the set of criteria related to the EU Ecolabel for Industrial and Institutional automatic Dishwasher Detergents. Its main purpose is to summarise the proposed criteria changes as well as provide a brief overview of background information related to each criterion and the rationale behind the proposal. Where these are common for different EU Ecolabel product groups and/or are due to harmonisation efforts, reference is made to a section of the Technical Annexe. Both documents, as well as the Preliminary Report, should be consulted to gain a full understanding of this revision process. It should be noted that the EU Ecolabel criteria for detergents for dishwashers (DD) are being revised in parallel. Due to the similarities in criteria, chemical constituents of the products involved and the overlap of stakeholders, a common Preliminary Report has been written. However, a separate Technical Report has been produced for each EU Ecolabel under revision. Nevertheless, as harmonisation of criteria across product groups is within the scope of this work, the rationale and commentary of the Technical Reports frequently compares and contrasts current criteria corresponding to the other detergent products being revised. A revision of EU Ecolabel criteria must ensure that, based on impacts of the products covered by the EU Ecolabel for "Industrial and Institutional automatic Dishwasher Detergents" at all life-cycle stages: The existing criteria are still relevant and that appropriately challenging targets, thresholds or usage information are established based on the latest knowledge of market norms, user behaviours, life-cycle impacts and hazards. Any new candidates for criteria suggested by either the LCA or the stakeholder survey are adequately considered and evaluation criteria justified. 1 Preliminary report for the revision of European Ecological Criteria: consumer and industrial and institutional automatic dishwasher detergents, available at: 1

5 Opportunities to rationalise criteria, i.e. remove, simplify and combine (within the group) or harmonise (between product groups), are examined and justified. The main criteria changes proposed in this report are updates of several criteria values and new values for categories of products that are not covered in the current criteria. 2

6 2 PRELIMINARY REPORT SUMMARY AND LINKS TO THE REVISION AND/OR DEVELOPMENT OF THE EU ECOLABEL CRITERIA The Preliminary Report presents the research carried out, through stakeholder surveys, market analysis, legal review and an environmental performance investigation, on areas related to the product group covered by the EU Ecolabel on Industrial and Institutional automatic Dishwasher Detergents. The preliminary report is a document that provides the background information and underpins the new criteria proposal for two product groups: Detergents for Dishwashers and Industrial and Institutional automatic Dishwasher Detergents, due to their multiple overlaps. The main findings of the Preliminary Report are: - The legal review revealed that the EU Detergents Regulation (EU) No 259/ will only impact on the consumer automatic dishwasher detergents on the market and not professional products. - The market analysis revealed that the market for dishwasher detergents is primarily intra- EU trade, with five large manufacturers accounting for 65% of the European market. The market for industrial and institutional kitchen and catering detergents (which includes dishwasher detergents) accounted for around 1,500 million in Europe in The technical analysis revealed that the key environmental impacts associated with the product group can be summarised as follows: The life cycle stage with the largest contribution to the environmental impact profile of industrial and institutional automatic dishwasher detergents is the use phase, particularly the energy needed to heat the water for the wash cycle. For some impact categories, the sourcing of raw materials is also important. Based on the normalisation assessment the most significant impact categories for dishwasher detergents in Europe are fossil depletion, climate change, human toxicity, particulate matter formation, and natural land transformation. The results of the LCA for a consumer dishwasher detergent conducted as part of the technical analysis showed that the environmental impacts are strongly correlated to each other via the energy use in the use phase (with the exception of natural land transformation). The use phase dominates the impact categories freshwater eutrophication, human toxicity, and marine ecotoxicity, whereas freshwater ecotoxicity and natural land transformation are dominated by ingredients sourcing. Due to the similarities between the two product groups, the environmental impact profile of the industrial and institutional dishwasher detergents are expected to be very close to that of consumer products. The key environmental performance indicators (KPIs), i.e. those variables that mainly drive the results for dishwasher detergents in Europe, based on the results of this study are (not ranked): Amount of product used per application, Choice of and amount of surfactant (although there are trade-offs between impact categories), Wash temperature, Energy source used to heat the water, Emissions to water. Apart from the LCA analysis, a revision of other scientific evidences, current national schemes and legislation have been performed. These sources of information pointed out the potential 2 Regulation (EU) No 259/2012 of the European Parliament and of the Council of 14 March 2012 amending Regulation (EC) No 648/2004 as regards the use of phosphates and other phosphorus compounds in consumer laundry detergents and consumer automatic dishwasher detergents, OJEU L 94/16 3

7 presence of hazardous substances in the product that can have environmental and health impacts, and these are addressed according to Articles 6.6 and 6.7 of the Regulation EC/66/2010 on the Ecolabel Regulation 3. This document shows the process and the evidences to draft the EU Ecolabel criteria that tackle the mentioned main environmental impacts identified through the LCA analysis and the non-lca impacts identified by revising other sources. The EU Ecolabel criteria are developed to directly or indirectly address the identified LCA and non-lca impacts (eg the choice and amount of surfactants is an environmental impact directly addressed through one or several EU Ecolabel criteria while the amount of detergent is indirectly addressed). The "energy source used to heat the water" is the only environmental impact that cannot be addressed through the EU Ecolabel as it is not directly linked to the products; even when consumers can choose the source of energy to heat the water or an electricity provider with a share of renewable energies, this is something out of the scope of what can be promoted through a product environmental label. Moreover, even though waste generation was not among the top 5 KPIs named previously, it can still have an impact of up to 11% for some environmental aspects. This environmental impact score can even being higher in the case of window cleaners. Given large amount of products used and the fact that they all come with packaging, a relatively small impact can quickly add up; thus, this aspect is also considered in the EU Ecolabel. Table 1 shows the link between the hotspots identified as LCA and non-lca impacts in the Preliminary Report and the revised or newly developed EU Ecolabel criteria. Table 1: Link between the hotspots identified (LCA and non-lca impacts) and the revised EU Ecolabel criteria % of total Revised or new EU Hotspots Comments in the related criteria impact 4 Ecolabel criteria Energy sources to heat up the water Amount of product used per application Formulation Choice of and amount of surfactant Formulation Choice of and % -- Out of the scope of this policy tool 2-32 % 2-32 % User information Automatic systems Biodegradability 2-32 % Colorants dosing Restricted substances Phosphorus content Sustainable Palm oil It informs users about the amount of product to be used depending on the washing conditions The criterion ensures that users do not use an incorrect dose when using multicomponent systems. It ensures that surfactants are degradable and will not persist in the environment It ensures that hazardous surfactants are not included in the bill of materials It ensures that limited and restricted types of phosphorus compounds are included as ingredients It ensures that renewable palm oil surfactants do not cause unnecessary strain on the ecosystem. It ensures that colorants do not accumulate in the water 3 Regulation (EC) No 66/2010 of the European Parliament and of the Council of November on the EU Ecolabel 4 Information provided in chapter 5 of the Preliminary Report, although aggregated in a different way, available at: 4

8 Hotspots amount of other ingredients Emissions water to Energy consumed to heat up the water Waste generation Water consumption Hazardous substances % of total impact % % 0-11 % Not rated Not rated Revised or new EU Ecolabel criteria Comments in the related criteria It ensures that only a limited amount of Fragrances ingredients with sensitizing properties is used Enzymes It ensures that enzymes cannot be inhaled limiting health risks for users Preservatives It ensures that no persistent or biocide preservatives are included as an ingredient Toxicity to aquatic It ensures that the sum of the ingredients is organisms not toxic to the aquatic organisms Biodegradability It ensures that ingredients are not persistent in the water Restricted substances It ensures that hazardous substances do not reach the water (rivers, see, oceans, etc) Colorants It ensures that colorants do not Fragrances accumulate, a limited use of ingredients Enzymes with sensitizing properties or are not Information appearing on the EU Ecolabel User Information Fitness for use Information appearing on the EU Ecolabel Packaging User Information User Information Hazardous substances and mixtures Ingoing substances listed in accordance with Article 59(1) of Regulation (EC) No 1907/2006 Information appearing on the EU Ecolabel inhaled It informs consumers that the product has a limited amount of hazardous substances while they are making purchase decisions It provides information to the users on how to wash to get the most of the product damaging the least the environment It ensures consumers that the product is fit to wash at lower temperature depending of the intended use It informs consumers that the product is fit for washing while they are making purchase decisions It ensures that limited amount of waste will be generated and that this waste can be recycled It reminds consumers to dispose of the packaging in a responsible manner The criterion encourages users to opt for wash loads. It provides information to the users on how to get the most out of the product while lowering the damage to the environment. It limits the hazardous substances and mixtures that can be included in the product limiting environmental and risks for consumers. It informs consumers that the product has a limited amount of hazardous substances at purchasing 5

9 3 SUMMARY OF THE FEEDBACK REQUESTED FROM STAKEHOLDERS INDUSTRIAL AND INSTITUTIONAL AUTOMATIC DISHWASHER DETERGENTS CRITERION SECTION QUESTIONS Toxicity to aquatic organisms 1 Should the CDV limits for multi-component products be stricter? If so please propose a suitable limit? 1 Do you agree with keeping the current criterion? Biodegradability What would be the appropriate limits for anbo and annbo? Could stakeholders please share with the project team data on 2 the amount of anbo and annbo organic substances and mixtures in the product groups covered? 1 Has DTPA used in Industrial and institutional automatic dishwasher detergents any feasible alternative on the market? Excluded or limited substances and 2 Should perborates be explicitly excluded from the IIDD (and DD) product group? mixtures 3 Are additional exclusions required for other substances? 1 Do you have information which could substantiate keeping/removing the current derogations. Excluded or limited substances and mixtures Phosphorus content Packaging 1 Should phosphorus compounds be excluded from this product group? 2 Can phosphates be substituted from IDD without increasing the chemical loading of sacrificing cleaning performance? 3 Do you agree with the proposed limits for phosphorous compounds? 4 Could the limits be stricter? 1 Packaging is not one of the top 5 KPIs for I&I dishwasher detergents, should a criterion related to it be kept? 2 Are the WUR limits appropriate? 3 Is the design for recycling requirement suitable for this product group? Automatic dosage 1 Is the criterion on multi-component products relevant to the product group? 1 Is the change to the dosage instruction wording acceptable? 2 Is a statement on overdosing required as part of the consumer information criterion? 3 Should information on use of renewable energy be included? User information 4 Should recycling labels be included on dishwasher detergent packaging? 5 Is it appropriate to have the information appearing on the EU Ecolabel as a separate criterion? (N.B. this is a horizontal issue relevant to other product groups) 6

10 4 CRITERIA STRUTURE COMPARISON TABLE Current organisation of the EU Ecolabel criteria Criterion 1: Toxicity to aquatic organisms: Critical Dilution Volume (CDV) Criterion 2: Biodegradability Criterion 3: Excluded or limited substances and mixtures Criterion 4: Packaging requirements Criterion 5: Washing performance (fitness for use) Criterion 6: Automatic dosing systems Criterion 7: User information Information appearing on the EU Ecolabel STRUCTURE OF THE CRITERIA Potential changes, modifications or amendments Criterion 1: Toxicity to aquatic organisms Criterion 2: Biodegradability Criterion 3: Sustainable sourcing of palm oil, etc. Criterion 4: Restricted substances Criterion 5: Packaging Criterion 6: Fitness for use Criterion 7: Automatic dosing systems Criterion 8: User information Criterion 9: Information appearing on the EU Ecolabel The proposed changes to the structure reflect the harmonisation across all detergents and cleaning products criteria documents. An additional criterion is proposed to cover sustainable sourcing of certain ingredients. 7

11 5 NAME AND DEFINITION COMPARISON TABLE Current name of the EU Ecolabel Industrial and institutional automatic dishwasher detergents The product group Industrial and Institutional Automatic Dishwasher Detergents shall comprise single and multi-component dishwasher detergents, rinse and pre-soaks, designed for use in professional dishwashers. The following products are excluded from the scope of this product group: consumer automatic dishwasher detergents, detergents intended to be used in washers of medical devices or in special machines for the food industry. Sprays not dosed via automatic pumps are excluded from this product group. NAME OF THE EU ECOLABEL Potential changes, modifications or amendments No changes DEFINITION OF THE PRODUCT GROUP The product group Industrial and Institutional Automatic Dishwasher Detergents shall comprise single and multi-component dishwasher detergents, rinse and pre-soaks, designed for use in professional dishwashers. Multi-component systems may incorporate a number of products including pre-soaks and rinsing agents. The following products are excluded from the scope of this product group: consumer automatic dishwasher detergents, detergents intended to be used in washers of medical devices or in special machines for the food industry. Sprays not dosed via automatic pumps are excluded from this product group. The proposed changes concern the clarification of what constitutes a multi-component system as concerns were raised on the issue. 8

12 6 COMPARISION OF EXISTING AND PROPOSED CRITERIA Existing EU Ecolabel criteria The Critical Dilution Volume (CDV chronic ) of a single or multi-component system must not exceed the following limits (at the highest recommended dose): CDV at the highest recommended dosage Soft Medium Hard Product type 0-6 dh 7-13 dh > 14 dh Pre-soaks Dishwasher detergents ,000 Multi-component system Rinse aids The Critical Dilution Volume (CDV chronic ) is calculated for all ingoing substances (i) in the product using the following equation: CDV = CDV(i) = 1000 dosage(i) DF(i) TF(i) Where: weight = the weight of the ingoing substance per recommended dose DF = the degradation factor TF = the chronic toxicity factor of the substance as stated in the DID list. Biocides and colouring agents present in the product shall also be included in the CDV calculation even if the concentration is lower than 0,010 % (100 ppm). Because of the degradation of the substances in the wash process, separate rules apply to the following substances: CRITERIA Criterion 1: Toxicity to aquatic organisms Potential changes, modifications or amendments The critical dilution volume (CDV) of the product must not exceed the following limits for the reference dosage: Soft Medium Hard Water hardness (<1,5 mmol (1,5 2,5 mmol (>2,5 mmol Product type CaCO3/l) CaCO3/l) CaCO3/l) Pre-soaks Dishwasher detergents Multi-component systems Rinse aids Assessment and verification: Calculation of the CDV of the product. A spreadsheet for calculation of the CDV value is available on the EU Ecolabel website. The Critical Dilution Volume (CDV) is calculated for all ingoing substances and mixtures (i) in the product using the following equation: CDV = CDV(i) = 1000 dosage(i) DF(i) TF(i) Where: dosage(i): weight (g) of the substance or mixture i in the reference dose, DF(i): degradation factor for the substance or mixture i TF(i): toxicity factor for the substance or mixture i The values of DF(i) and TF(i) shall be as given in the DID list Part A (Appendix I 5 ). If a substance or mixture is not included in the DID list Part A, the applicant shall estimate the values follow the approach described in the DID list Part B (Appendix 5 The "Appendix" referred to in the criteria text is the Appendix found at the end of EU Ecolabel criteria and has not been formulated as of the writing of this report. It does not refer to the Appendixes found at the end of this Technical Report. 9

13 Hydrogen Peroxide (H2O2) not to be included in calculation of CDV, Peracetic acid to be included in the calculation as acetic acid. Assessment and verification the applicant shall provide the calculation of the CDV chronic of the product. A spreadsheet for calculation of the CDV value is available on the EU Ecolabel website. The values of the DF and TF parameters shall be as given in the Detergent Ingredient Database list (DID list). If the substance is not found on the DID list, the parameters shall be calculated using the guidelines in Part B of the DID list and attaching the associated documentation (a) Biodegradability of surfactants All surfactants must be biodegradable under aerobic and anaerobic conditions. (b) Biodegradability of organic substances The content of all organic substances in the product that are aerobically nonbiodegradable (not readily biodegradable) (anbo) and anaerobically nonbiodegradable (annbo) shall not exceed the following limits: anbo (aerobically non-biodegradable) Product type Soft Medium Hard (g/l washing solution) 0-6 dh 7-13 dh > 14 dh Pre-soaks Dishwasher detergents/ Multicomponent system Rinse aids annbo (anaerobically non-biodegradable) Product type Soft Medium Hard (g/l washing solution) 0-6 dh 7-13 dh > 14 dh Pre-soaks Dishwasher detergents/ Multicomponent system Criterion 2: Biodegradability of organics I). Because of the degradation of the substances in the wash process, separate rules apply to the following substances: hydrogen peroxide (H 2O 2) not to be included in calculation of CDV peracetic acid to be included in the calculation as acetic acid. The proposed changes refer to the name of the criterion that is brought in line with other EU Ecolabel criteria for detergents as well as the units expressing the hardness of water. a) Biodegradability of surfactants All surfactants shall be biodegradable under aerobic conditions. All surfactants shall be biodegradable under anaerobic conditions b) Biodegradability of organic substances and mixtures The content of organic substances and mixtures in the product that are aerobically non-biodegradable (not readily biodegradable anbo) or anaerobically non-biodegradable (annbo) shall not exceed the following limits for the reference dosage: anbo (g/l washing solution) Soft Medium Hard Water hardness <1,5 1,5 2,5 > 2,5 Product type mmol CaCO 3/l mmol CaCO 3/l mmol CaCO 3/l Pre-soaks 0,4 0,4 0,4 Dishwasher detergents/ Multicomponent system 0,4 0,4 0,4 Rinse aids 0,04 0,04 0,04 annbo (g/l washing solution) 10

14 Rinse aids Assessment and verification: the applicant shall provide documentation for the degradability of surfactants as well as the calculation of anbo and annbo for the product. A spreadsheet for use in calculating anbo and annbo values is available on the EU Ecolabel website. For both surfactants and anbo and annbo values reference should be done to the DID List. For ingoing substances which are not included in the DID list, the relevant information from literature or other sources, or appropriate test results, showing that they are aerobically and anaerobically biodegradable shall be provided as described in Appendix I. Note that TAED should be considered anaerobically biodegradable. In the absence of documentation in accordance with the above requirements, a substance other than a surfactant may be exempted from the requirement for anaerobic degradability if one of the following three alternatives is fulfilled: 1. Readily degradable and has low adsorption (A < 25 %); or 2. Readily degradable and has high desorption (D > 75 %); or 3. Readily degradable and non-bioaccumulating. Testing for adsorption/desorption may be conducted in accordance with OECD guidelines 106. Soft Medium Hard Water hardness <1,5 1,5 2,5 > 2,5 Product type mmol CaCO 3/l mmol CaCO 3/l mmol CaCO 3/l Pre-soaks 0,4 0,4 0,4 Dishwasher detergents/ Multicomponent system 0,6 1,0 1,5 Rinse aids 0,04 0,04 0,04 Assessment and verification: The applicant shall provide documentation for the degradability of surfactants, as well as the calculations of anbo and annbo for the product. A spreadsheet for use in calculating anbo and annbo values is available on the EU Ecolabel website. For both surfactants and anbo and annbo values, reference shall be made to the DID List. For ingredients which are not included in the DID List, the relevant information from literature or other sources, or appropriate test results, showing that they are aerobically and anaerobically biodegradable shall be provided as described in Appendix I. In the absence of documentation in accordance with the above requirements, an ingoing substances and mixtures other than a surfactant may be exempted from the requirement for anaerobic degradability if one of the following three alternatives is fulfilled: 1. Readily degradable and has low adsorption (A < 25%,); 2. Readily degradable and has high desorption (D > 75%); 3. Readily degradable and non-bioaccumulating. Testing for adsorption/desorption may be conducted in accordance with OECD guidelines 106. As six EU Ecolabels related to detergents are being revised at the same time and as these products often have similar formulations, it is judicious to consider the harmonisation of their criteria. The current six EU Ecolabel criteria approach the subject using three different manners and stakeholder consultation has yielded a multitude of opinions. It has thus been decided that a discussion during the 1 st AHWG meeting will be held. As a starting point for the harmonised approach, the criterion included in the most recently voted criteria for industrial and institutional products (laundry and dishwasher detergents) is proposed. The criterion will be revised following discussions with stakeholders. Collection of data on anbo and 11

15 annbo is conducted. Criterion 3 Excluded or limited substances and mixtures (a) Specified excluded ingoing substances The following ingoing substances must not be included in the product, neither as part of the formulation nor as part of any mixture included in the formulation: EDTA (ethylenediamine tetraacetate),en L 326/28 Official Journal of the European Union Fragrances, Reactive chlorine compounds, APEO (Alkyl phenol ethoxylates) and APD (Alkylphenols and derivatives thereof). Assessment and verification: the applicant shall provide a completed and signed declaration of compliance. (a) Specified excluded ingoing substances The product shall not be formulated or manufactured using any of the following compounds: (i) Phosphates (ii) Phosphonates that are not readily biodegradable (iii) Ethylenediaminetetraacetate (EDTA) and its salts (iv) Fragrances (v) Reactive chlorine compounds (vi) Alkylphenol ethoxylates (APEO) and alkylphenol derivatives (APD) (vii) Perborates (viii) Diethylenetriaminepentaacetic acid (DTPA) (b) Hazardous substances and mixtures According to the Article 6(6) of Regulation (EC) No 66/2010 on the EU Ecolabel, the product or any component of it shall not contain substances meeting criteria for classification with the hazard statements or risk phrases specified below in Assessment and verification: the applicant shall provide: a) a signed declaration of compliance supported by declarations from manufacturers of mixtures, as appropriate, confirming that the listed substances and/or mixtures have not been included in the product. b) written statements on compliance, including: - information on the complexing agents in the product (detail information of the type of phosphonates added as ingredients); - information for the biodegradability of the phosphonates. A spreadsheet for use in calculating anbo values is available on the EU Ecolabel website. For anbo values reference should be done to the DID List. For phosphonates which are not included in the most updated DID list, the relevant information from literature or other sources, or appropriate test results, showing that they are aerobically biodegradable shall be provided as described in Appendix I. (b) Hazardous substances and mixtures According to Article 6(6) of Regulation (EC) No 66/2010, the EU Ecolabel may not be awarded to any product that contains substances meeting criteria for classification with the hazard statements specified in the list below in accordance with Regulation (EC) No 1272/2008 of the European Parliament and of the Council or substances referred to in Article 57 of Regulation (EC) No 1907/

16 accordance with Regulation (EC) No 1272/2008 of the European Parliament and of the Council ( 1 ) or Council Directive 67/548/EEC nor shall it contain substances referred to in Article 57 of Regulation (EC) No 1907/2006. The risk phrases below generally refer to substances. However, if information on substances cannot be obtained, the classification rules for mixtures apply. List of hazard statements: GHS Hazard Statement EU Risk Phrase H300 Fatal if swallowed R28 H301 Toxic if swallowed R25 H304 May be fatal if swallowed and enters airways R65 H310 Fatal in contact with skin R27 H311 Toxic in contact with skin R24 H330 Fatal if inhaled R23/26 H331 Toxic if inhaled R23 H340 May cause genetic defects R46 H341 Suspected of causing genetic defects R68 H350 May cause cancer R45 H350i May cause cancer by inhalation R49 H351 Suspected of causing cancer R40 H360F May damage fertility R60 H360D May damage the unborn child R61 H360FD May damage fertility. May damage the unborn child R60/61/60-61 H360Fd May damage fertility. Suspected of damaging the unborn child R60/63 H360Df May damage the unborn child. Suspected of damaging fertility R61/62 H361f Suspected of damaging fertility R62 H361d Suspected of damaging the unborn child R63 H361fd Suspected of damaging fertility. Suspected of damaging the unborn child. R62-63 H362 May cause harm to breast fed children R64 H370 Causes damage to organs R39/23/24/25/ 26/27/28 H371 May cause damage to organs R68/20/21/22 The hazard statements in Table 2 generally refer to substances. However, if information on substances cannot be obtained, the classification rules for mixtures apply. Substances or mixtures which change their properties through processing and thus become no longer bioavailable, or undergo chemical modification in a way that removes the previously identified hazard are exempted from criterion X(b). Table 2: Hazard statements GHS Hazard Statement H300 Fatal if swallowed H301 Toxic if swallowed H304 May be fatal if swallowed and enters airways H310 Fatal in contact with skin H311 Toxic in contact with skin H330 Fatal if inhaled H331 Toxic if inhaled H340 May cause genetic defects H341 Suspected of causing genetic defects H350 May cause cancer H350i May cause cancer by inhalation H351 Suspected of causing cancer H360F May damage fertility H360D May damage the unborn child H360FD May damage fertility. May damage the unborn child H360Fd May damage fertility. Suspected of damaging the unborn child H360Df May damage the unborn child. Suspected of damaging fertility H361f Suspected of damaging fertility H361d Suspected of damaging the unborn child H361fd Suspected of damaging fertility. Suspected of damaging the unborn child. H362 May cause harm to breast fed children H370 Causes damage to organs H371 May cause damage to organs 13

17 H372 Causes damage to organs through prolonged or repeated exposure R48/25/24/23 H373 May cause damage to organs through prolonged or repeated exposure R48/20/21/22 H400 Very toxic to aquatic life R50 H410 Very toxic to aquatic life with long-lasting effects R50-53 H411 Toxic to aquatic life with long-lasting effects R51-53 H412 Harmful to aquatic life with long-lasting effects R52-53 H413 May cause long-lasting harmful effects to aquatic life R5R593 EUH059 Hazardous to the ozone layer R29 EUH029 Contact with water liberates toxic gas R29 EUH031 Contact with acids liberates toxic gas R31 EUH032 Contact with acids liberates very toxic gas R32 EUH070 Toxic by eye contact R39-41 Sensitising substances H334: May cause allergy or asthma symptoms or breathing difficulties if inhaled R42 H317: May cause allergic skin reaction R43 Note that this criterion also applies to known degradation products such as formaldehyde from formaldehyde releasers. Substances or mixtures which change their properties through processing (e.g. become no longer bioavailable, or undergo chemical modification in a way that removes the previously identified hazard) are exempted from the above requirement. The final product must not be labelled according to the hazard statements above. Derogations The following substances are specifically exempted from this requirement H372 Causes damage to organs through prolonged or repeated exposure H373 May cause damage to organs through prolonged or repeated exposure H400 Very toxic to aquatic life H410 Very toxic to aquatic life with long-lasting effects H411 Toxic to aquatic life with long-lasting effects H412 Harmful to aquatic life with long-lasting effects H413 May cause long-lasting harmful effects to aquatic life EUH059 Hazardous to the ozone layer EUH029 Contact with water liberates toxic gas EUH031 Contact with acids liberates toxic gas EUH032 Contact with acids liberates very toxic gas EUH070 Toxic by eye contact Sensitising substances H334: May cause allergy or asthma symptoms or breathing difficulties if inhaled H317: May cause allergic skin reaction This criterion applies to all ingredients present in concentrations 0,01 %, including preservatives, colouring agents and fragrances. For industrial and institutional automatic dishwasher products, the substances in Table 3 are exempted from the obligation in Article 6(6) of Regulation (EC) No 66/2010 following application of Article 6(7) of the same Regulation. Table 3: Derogated substances - To be discussed in the 1st AHWG meeting Derogated substance H phrases Assessment and verification: the applicant shall demonstrate compliance with criterion X(b) for any ingoing substance or mixture present at concentrations greater than 0,010% in the product. A declaration of compliance shall be provided by the applicant supported, where appropriate, by the declarations from producer(s) of the raw materials that none of these ingoing substances and/or mixtures meet the criteria for classification 14

18 Surfactants In concentrations <15 % in the final product Surfactants In concentrations <25 % in the final product Biocides used for preservation purposes (*) (only for liquids with ph between 2 and 12 and maximum 0.10 % w/w of active material) Enzymes (**) NTA as an impurity in MGDA and GLDA (***) H400 Very toxic to aquatic life H412 Harmful to aquatic life with long-lasting effects H331: Toxic if inhaled H334: May cause allergy or asthma symptoms or breathing difficulties if inhaled H317: May cause allergic skin reaction H400: Very toxic to aquatic life H334: May cause allergy or asthma symptoms or breathing difficulties if inhaled H317: May cause allergic skin reaction H400: Very toxic to aquatic life H351 suspected of causing cancer R50 R52-53 R50-53 R51-53 R52-53 R43 R42 Assessment and verification the applicant shall demonstrate compliance with this criterion by providing a declaration on the non-classification of each ingoing substance into any of the hazard classes associated to the hazard statements referred to in the above list in accordance with Regulation (EC) No 1272/2008, as far as this can be determined, as a minimum, from the information meeting the requirements listed in Annex VII to Regulation (EC) No 1907/2006. This declaration shall be supported by summarised information on the relevant characteristics associated to the hazard statements referred to in the above list, to the level of detail specified in Sections 10, 11 and 12 of Annex II to Regulation (EC) No 1907/2006 (Requirements for the Compilation of Safety Data Sheets). Information on intrinsic properties of substances may be generated by means other than tests, for instance through the use of alternative methods such as in vitro methods, by quantitative structure activity models or by the use of grouping or read-across in accordance with Annex XI to Regulation (EC) No 1907/2006. The R40 with one or more of hazard statements listed in the form(s) and physical state(s) they are present in the product. The following technical information related to the form(s) and physical state(s) of the ingoing substances and/or mixtures as present in the product shall be provided to support the declaration of non-classification: (i) For substances that have not been registered under Regulation (EC) No 1907/2006 and/or which do not yet have a harmonised CLP classification: Information meeting the requirements listed in Annex VII to that Regulation; (ii) For substances that have been registered under Regulation (EC) No 1907/2006 and which do not meet the requirements for CLP classification: Information based on the REACH registration dossier confirming the non-classified status of the substance; (iii) For substances that have a harmonised classification or are self-classified: safety data sheets where available. If these are not available or the substance is self-classified then information shall be provided relevant to the substances hazard classification according to Annex II to Regulation (EC) No 1907/2006; (iv) In the case of mixtures: safety data sheets where available. If these are not available then calculation of the mixture classification shall be provided according to the rules under Regulation (EC) No 1272/2008 together with information relevant to the mixtures hazard classification according to Annex II to Regulation (EC) No 1907/2006. For substances listed in Annexes IV and V to Regulation (EC) No 1907/2006, which are exempted from registration obligations under point (a) and (b) of Article 2(7) of that Regulation, a declaration to this effect by the applicant shall suffice to comply with criterion X(b). A declaration on the presence of ingoing substances that fulfil the derogation conditions shall be provided by the applicant, supported, where appropriate, by declarations from the producer(s) of the raw materials. Where required for the derogation, the applicant shall confirm the concentrations of these ingoing substances in the final product. 15

19 sharing of relevant data is strongly encouraged. The information provided shall relate to the forms or physical states of the substance or mixtures as used in the final product. For substances listed in Annexes IV and V to REACH, exempted from registration obligations under Article 2(7)(a) and (b) of Regulation (EC) No 1907/2006 REACH, a declaration to this effect will suffice to comply with the requirements set out above. (c) Substances listed in accordance with Article 59(1) of Regulation (EC) No 1907/2006 No derogation from the exclusion in Article 6(6) of the Regulation (EC) No 66/2010 shall be given concerning substances identified as substances of very high concern and included in the list foreseen in Article 59 of Regulation (EC) No 1907/2006, present in mixtures in concentrations > 0,010 %. Assessment and verification the list of substances identified as substances of very high concern and included in the candidate list in accordance with Article 59 of Regulation (EC) No 1907/2006 can be found here: eu/chem_data/authorisation_process/candidate_list_table_en.asp Reference to the list shall be made on the date of application. The applicant shall provide the exact formulation of the product to the competent body. The applicant shall also provide a declaration of compliance with this criterion, together with related documentation, such as declarations of compliance signed by the material suppliers and copies of relevant Safety Data Sheets for substances or mixtures. (c) Substances listed in accordance with Article 59(1) of Regulation (EC) No 1907/2006 No derogation from the exclusion in Article 6(6) of Regulation (EC) No 66/2010 shall be given concerning ingoing substances identified as substances of very high concern and included in the list provided for in Article 59(1) of Regulation (EC) No 1907/2006 6, present in the product in concentrations higher than 0.010% (weight by weight). Assessment and verification: reference to the list of substances identified as substances of very high concern shall be made on the date of application. The applicant shall provide the full formulation of the product to the competent body. The applicant shall also provide a declaration of compliance with criterion X(c), together with related documentation, such as declarations of compliance signed by the material suppliers and copies of relevant safety data sheets for substances or mixtures. (d) Specified limited ingoing substances Biocides (i) The product may only include biocides in order to preserve the product, and in the appropriate dosage for this purpose alone. This does not refer to surfactants, which may also have biocidal properties. Assessment and verification the applicant shall provide copies of the material safety data sheets of any biocides added, together with information on their exact concentration in the product. The manufacturer or supplier of the biocides shall (d) Specified limited ingoing substances Preservatives (i) considered bioaccumulating if BCF < 100 or logpow < 3,0. If both BCF and log K ow values are available, the highest measured BCF value shall be used. (ii) Preservatives in the product shall not release or degrade to substances that are classified in accordance with the requirements of criterion x(b) Hazardous substances and mixtures

20 provide information on the dosage necessary to preserve the product. (ii) It is prohibited to claim or suggest on the packaging or by any other communication that the product has an antimicrobial or disinfecting effect. Assessment and verification the applicant shall provide the texts and layouts used on each type of packaging and/or an example of each different type of packaging to the competent body. (iii) The product may contain biocides provided that they are not bioaccumulating. A biocide is not considered bioaccumulating if BCF < 100 or logkow < 3,0. If both BCF and logkow values are available, the highest measured BCF value shall be used. Assessment and verification the applicant shall provide copies of the material safety data sheets of any biocide added, together with information on their BCF and/or logk ow values. (iii) It is prohibited to claim or suggest on the packaging or by any other communication that the product has an antimicrobial action. Assessment and verification: the applicant shall provide a signed declaration of compliance, together with copies of the safety data sheets of any preservative added, and information on its BCF and/or log K ow values. The applicant shall provide also artwork of the packaging. (e) Colouring agents Colouring agents allowed in the product must not be bioaccumulating. In the case of colouring agents approved for use in foodstuffs it is not necessary to submit documentation of bioaccumulation potential. A colouring agent is considered not bioaccumulating if BCF < 100 or logkow < 3,0. If both BCF and logkow values are available, the highest measured BCF value shall be used. Assessment and verification the applicant shall provide copies of the material safety data sheets of any colouring agents added, or documentation to ensure that the colouring agent is approved for use in foodstuff. (e) Colorants Colorants in the product must not be bioaccumulating. A colorant is considered not bioaccumulating if BCF < 100 or logpow < 3.0. If both BCF and log K ow values are available, the highest measured BCF value shall be used. In the case of colouring agents approved for use in food, it is not necessary to submit documentation of bioaccumulation potential. Assessment and verification: the applicant shall provide copies of the safety data sheets of any colorant added together with information on its BCF and/or log K ow value, or documentation to ensure that the colouring agent is approved for use in food. (f) Enzymes Enzymes must be in liquid form or dust-free granulate. Enzymes must be free from micro-organism remnants from manufacture. Assessment and verification the applicant shall provide copies of the material safety data sheets of any enzyme added, together with documentation to ensure that the enzyme is free from micro-organism remnants. (f) Enzymes Enzymes must be in liquid form or dust-free granulate. Enzymes must be free from micro-organism remnants from manufacture. Assessment and verification: the applicant shall provide copies of the material safety data sheets of any enzyme added, together with documentation to ensure that the enzyme is free from micro-organism remnants. 17

21 (g) Phosphorous content The total quantity of phosphates and other phosphorous compounds must not exceed the limit values specified in table, calculated in grams of phosphorous per litre water. The highest recommended dosage shall be used for the phosphorous calculations. Product type Soft Medium Hard Phosphorous(g P/l water) 0-6 dh 7-13 dh > 14 dh Pre-soaks Dishwasher detergents Rinse aids Multi-component system Assessment and verification: the applicant shall provide documentation to ensure that the limit in the above table is fulfilled. (g) Phosphorous content The total quantity of phosphorus compounds must not exceed the limit values specified in the table below: Product type Phosphorous(g P/l water) Water hardness (mmolcaco 3/l) Soft Medium Hard (<1.5) ( ) (>2.5) Pre-soaks Dishwasher detergents Rinse aids Multi-component system Assessment and verification The applicant shall provide written statements on compliance, including: - information on the complexing agents in the product (detail information of the type of phosphorus-content substances added as ingredients); - information on the recommended dose for different levels of soiling or water hardness (when applicable); - calculation of the product s total P-content The proposed changes are focused on the following issues: - the proposal for including perborates, DTPA, APD and their derivatives. Further input for this section is expected during the 1 st AHWG meeting. - "Preservatives" substitute the current restrictions on biocides. This changes is motivated by the difficulties in verification of the current criterion, the need of addressing safe preservatives that do not release or degrade into other hazardous substances and ensuring the not bioaccumulation of the preservatives. - "Colorants" includes a change in the name from "colouring agents" to "colorants" and the inclusion that no information is needed to be submitted when colorants used in foodstuff are added. - Phosphonates that are not readily biodegradable are proposed to be excluded. The verification procedure has been changed in accordance. 18

22 (a) Weight/utility ratio (WUR) The weight/utility ratio (WUR) of the product shall not exceed the following values: Product type Soft Medium Hard 0-6 dh 7-13 dh > 14 dh Powders (g/l washing solution) Liquids (g/l washing solution) WUR shall be calculated only for primary packaging (including caps, stoppers and hand pumps/spraying devices) using the formula below: Where: W i = the weight (g) of the packaging component (i) including the label if applicable U i = the weight (g) of non-recycled (virgin) material in the packaging component (i). If the proportion of recycled material in the packaging component is 0 % then U i = W i. D i = the number of functional units contained in the packaging component (i). The functional unit = dosage in g/l washing solution. r i = recycling figure, i.e. the number of times the packaging component (i) is used for the same purpose through a return or refill system. r = 1, if the packaging is not reused for the same purpose. If the packaging is reused r is set to 1 unless the applicant can document a higher number. Exceptions Plastic/paper/cardboard packaging containing more than 80 % recycled material or more than 80 % plastic from renewable origin is exempted from this requirement. Packaging is regarded as recycled if the raw material used to make the packaging has been collected from packaging manufacturers at the distribution stage or at the consumer stage. Where the raw material is industrial waste from the material manufacturer s own production process, then the material will not be regarded as recycled. Assessment and verification the applicant shall provide the calculation of the Criterion 4 Packaging a) Weight/utility ratio (WUR) The weight/utility ratio (WUR) of the product shall be calculated for the primary packaging only and shall not exceed the following values for the reference dosage: Water hardness Product type Soft Medium Hard <1,5 mmol CaCO3/l 1.5 2,5 mmol CaCO3/l > 2,5 mmol CaCO3/l Powders 0,8 g 1,4 g 2,0 g Liquids 1,0 g 1,8 g 2,5 g Are exempted from this requirement: - Plastic/paper/cardboard packaging containing more than 80 % recycled materials, - Paper/cardboard packaging that comes 80% from certified sustainable sources, - Plastic packaging containing more than 80 % plastic from sustainable sources. Assessment and verification: the applicant shall provide the calculation of the WUR of the product. A spreadsheet for this calculation is available on the EU Ecolabel website. If the product is sold in different packaging (i.e. with different volumes), the calculation shall be submitted for each packaging size for which the EU Ecolabel shall be awarded. The applicant shall provide a completed and signed declaration for the content of recycled material in the packaging. - For paper and cardboard, packaging is regarded as recycled if the raw material used to make the packaging has been collected from packaging manufacturers at the distribution stage or at the consumer stage. Where the raw material is industrial waste from the material manufacturer s own production process, then the material will not be regarded as recycled. - For plastic, packaging is regarded as recycled if the raw material used to make the packaging comes from industrial waste or has been collected from packaging manufacturer at the distribution or at the consumer stage. The applicant shall provide a completed and signed declaration for the content of 19